Short answer. Usually yes. The Civil Code lets the tenant remove ornamental objects he installed, provided no damage is caused to the principal thing — unless the landlord chooses to keep them by paying their value when the lease ends. For decorations, though, the tenant gets no reimbursement.
What the law says
With regard to ornamental expenses, the lessee shall not be entitled to any reimbursement, but he may remove the ornamental objects, provided no damage is caused to the principal thing, and the lessor does not choose to retain them by paying their value at the time the lease is extinguished.
Civil Code, Article 1678 — Useful Improvements by the Lessee. Read the full provision →
Ornamental objects follow a special rule
Article 1678 treats decorations differently from useful improvements. On ornaments it says: with regard to ornamental expenses, the lessee shall not be entitled to any reimbursement, but he may remove the ornamental objects, provided no damage is caused to the principal thing, and the lessor does not choose to retain them by paying their value. So the starting point is that mirrors, decorative panels, fancy light fixtures, and similar embellishments you put up are yours to take when you go. The trade-off is that, unlike genuinely useful improvements, purely ornamental spending earns you no reimbursement while the lease runs or at its end.
The 'no damage' condition
The right to remove is not unlimited. It is conditioned on causing no damage to the principal thing — the unit itself. If prying a decoration off the wall would gouge the plaster, crack the tiles, or tear out part of the structure, the tenant cannot simply rip it away. The law protects the property from being harmed in the name of recovering ornaments. In practice this means removal is allowed where the object can come off cleanly, and may not be where the decoration was embedded so deeply that taking it out would injure the unit.
The landlord's option to keep them
Even where the tenant could remove an ornament, the landlord holds a counter-right: he may choose to retain them by paying their value at the time the lease is extinguished. If the landlord likes the decorations and wants them to stay, he can keep them by paying what they are worth at the end of the lease, and the tenant then leaves them behind. This puts the final say with the landlord for ornaments he values, while still compensating the tenant for their worth. The value is measured at the moment the lease ends, not what the tenant originally spent.
Before you strip the walls
Two practical points. First, distinguish true ornaments from useful improvements, because reimbursement rules differ — a fixture that makes the unit more usable is treated under a different part of the same article. Second, weigh whether removal can be done without damaging the unit, since damage forfeits the right and can leave you liable for repairs. If the landlord offers to pay for the ornaments, that ends the matter in his favor. Because the line between ornamental and useful, and the extent of any damage, are fact-specific, review your situation carefully before removing anything.
Cases citing this provision
These Supreme Court decisions cite the provision above. We list them so you can read them yourself; the summaries of what each decided are not ours to give.
- Henry L. Sia vs. Court of Appeals, et al, G.R. No. 108222, May 5, 1997 — read the decision on LawPhil →
- Bermon Marketing Communication Corporation vs. Spouses Lilia M. Yaco and Nemesio Yaco, G.R. No. 224552, March 3, 2021 — read the decision on LawPhil →
- Marguerite J. Lhuillier vs. The Hon. Court of Appeals, G.R. No. 128058, December 19, 2000 — read the decision on LawPhil →
- Spouses Crispin Aquino and Teresa V. Aquino, herein represented by their Attorney-in-fact, Amador D. Ledesma vs. Spouses Eusebio Aguilar and Josefina V. Aguilar, G.R. No. 182754, June 29, 2015 — read the decision on LawPhil →